Human Factors Implications

The three-part document, which addresses all aspects of Maintenance SMS for operators and regulatory authorities, is nearly 500 pages. EASA considers not only safety but also costs.

The European Aviation Safety Agency (EASA) has published proposed amendments for safety management systems (SMS). Johnson, sticks to the facts and sorts out the portions of rule that may impact the 1,200 plus EASA Part 145 repair stations in the United States.

NPA 2013-1 Safety Management Systems for Maintenance Organizations

The code is simple. EASA published a Notice of Proposed Amendment (NPA) on Jan. 21, 2013 (EASA NPA 2013-1). The comment period closes on May 22, 2013. You will be able to see the comments at in the Comment-Response Document (CRD) once it is published.

The three-part document, which addresses all aspects of Maintenance SMS for operators and regulatory authorities, is nearly 500 pages. That is not a problem since Part A contains an excellent 30-page summary (NPA 2013-01 (A). Most of the information presented below is based on NPA 2013-01 (C) ‘Part 145’, which is about 180 pages. The documents are clear, readable, and understandable. You won’t need a lawyer by your side. EASA has done an excellent job to clarify the rationale for the proposed SMS rules and the impact of the rules for maintenance organizations. EASA considers not only safety but also costs as exemplified by the following:

… Moreover, the causes and contributing factors of incidents and accidents are very often causing or contributing to production losses or inefficiencies … Effective management systems will, therefore, contribute to a decrease in insurance costs, improved reputation, and commercial success …” page 24 of Part A.

In the Executive Summary, the document stressed that the primary goal of the proposed changes is to ensure adherence to the international SMS framework established by ICAO (Annex 19). That includes review and modifications to EASA’s current guidance on human factors. EASA says that the proposed changes strive to be flexible and can be proportioned to the size of the organization. It plans to issue another NPA for Part 66 (Personnel Certification) and Part 147 (Training Organizations) in the next stage.

SMS comments

One gets the hint that this NPA has an HF perspective when you read the description of the classic probability-severity matrix. Even before the document addresses human factors they use maintenance fatigue as an example for risk management and include specific accident examples.

“… Maintenance personnel fatigue crystallizes as an area requiring specific attention … Fatigue is an intrinsic aspect of all scheduled or unscheduled maintenance operations … Numerous studies have shown that all of these conditions heighten aircraft maintenance personnel fatigue in their daily tasks. Consequently, the NPA stresses the importance of managing safety hazards stemming from maintenance personnel fatigue and proposes the implementation of a safety risk management scheme …” (Pages 20-21 of Part A).

In an effort to clarify descriptions EASA did some universal wording changes. For example, the term “quality system” is now “compliance monitoring system.” EASA ensured consistent numbering between the regulation and the Acceptable Means of Compliance (AMC). There is also a helpful 25-page table that specifies the “type” of proposed regulation change and a “description.”

Selected human factors changes

In a perfect harmonized world the proposed changes would have no impact on an organization that is structuring its SMS to ICAO guidelines. Such guidelines would likely satisfy all National Aviation Authorities (NAA), including FAA. However, in the real world, NAA interpretation of the ICAO framework varies. That is particularly true with respect to human factors (HF) requirements. The interpretation of HF, at EASA, is more prescriptive than the FAA’s. Therefore EASA Part 145 Certificate holders must include HF requirements. As with all EASA rules AMC defines how to implement the regulation. The AMC is in Part C and is used here. Let’s look at a few examples that could affect U.S.-based EASA 145 certificate holders.

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